Third Circuit Sustains Summary Judgment in Favor of KM&M Client in Discrimination/Retaliation Suit
The U.S. Court of Appeals for the Third Circuit has affirmed a lower court decision granting summary judgment in favor of KM&M's client, a major offset printing company, in a race discrimination and retaliation case. The plaintiff in Morris v. Scott Printing Corp., a self-styled "labor activist," was employed as a lithographic press operator. He was demoted to a lower rated position when the workforce was reduced and various other employees were laid off. Morris filed a charge of discrimination with the Equal Employment Opportunity Commission ("EEOC"), alleging that he had been demoted because of his race. Thereafter, Morris received a series of disciplinary warnings for poor work performance and inappropriate workplace conduct; he filed another EEOC charge, claiming that the warnings were issued in retaliation for his earlier charge. Finally, as a result of another workforce reduction, Morris and seven other employees were laid off. With the sole exception of Morris, the laid off employees were subsequently recalled to work when business improved.
Morris filed suit in U.S. District Court in New Jersey, asserting all of the claims included in his EEOC charges and alleging that Scott's failure to recall him to work was the result of discrimination and retaliation. The District Court granted Scott's motion for summary judgment, dismissing all of Morris's claims. The court found that Scott had demonstrated legitimate non-discriminatory reasons for each of the personnel actions affecting Morris, and that he was unable to show that those reasons were a pretext for racial discrimination or retaliation. The Court of Appeals agreed, finding that there was no evidence to support his claim that he was demoted because of his race, and that there was insufficient evidence of a causal connection between Morris's EEOC charges and his subsequent warnings or layoff to merit a trial with respect to his retaliation claims. Accordingly, the Court of Appeals affirmed the dismissal of the case.